Pacific Capital Real Estate Ltd. Privacy Policy
This privacy policy was last updated on: December 11, 2024
This privacy policy (“Privacy Policy”) sets out how Pacific Capital Real Estate Ltd., [its subsidiaries and its other affiliates and related entities] (“PATH”, “we“, “us” and “our“) manage, collect, use, disclose and hold personal information about you via our websites (collectively, the “Websites”), when you access or use our services or apply for a job with us, and in other interactions with us (collectively, our “Services”). The expressions “you” and “your” refer to each and every individual whose personal information we may handle from time to time.
BY SUBMITTING PERSONAL INFORMATION TO US, YOU CONSENT TO OUR COLLECTION, USE AND DISCLOSURE OF SUCH PERSONAL INFORMATION IN ACCORDANCE WITH THIS PRIVACY POLICY AND AS PERMITTED OR REQUIRED BY LAW. Subject to legal and contractual requirements, you may refuse or withdraw your consent to our collection, use, storage, transfer, disclosure, or communication (collectively, “processing” or “process”) of your personal information at any time by contacting our Privacy Officer, whose contact information is set out below. If you refuse or withdraw your consent, we may not be able to provide or continue to provide you with products, services or information which may be of value to you.
Please review this Privacy Policy before providing us with your personal information, including through the use of the Websites. IF YOU DO NOT AGREE WITH THIS PRIVACY POLICY, DO NOT PROVIDE US WITH YOUR PERSONAL INFORMATION OR USE THE WEBSITES.
This Privacy Policy is divided into the following sections.
1. Collection Of Personal Information
Personal information means any information which relates to a natural person and allows that person to be identified directly, or indirectly in combination with other information. It does not include personal information where all references to the identity of the relevant individual have been removed (i.e., anonymous personal information).
We may collect and process the following categories of personal information about you:
- Identity personal information, including first name, last name, preferred name and title.
- Contact personal information, including email, address, postal code, and telephone numbers.
- Shareholder information, including shareholdings in the PATH.
- Technical personal information, includinginternet protocol (IP) address and geolocation information, cookies and other technology on the devices you use to access the Websites.
- Internet activity information, including browsing history, search history, and interactions with our Websites and online advertisements. In addition, we may collect information about your browsing behaviour, such as the date and time you visit the Websites, the areas or pages of the Websites that you visit, the amount of time you spend viewing the Websites, the number of times you return to the Websites, the websites that you visit before or after you visit our Websites and other click-stream data.
- Career profile personal information, including your resume, cover letter, language proficiency, and other information that you choose to add to your application for one of our roles.
- Real estate information, including your interests, preferences, reasons for buying or renting, and budget range.
If you provide PATH with the personal information of another individual, you represent that you have obtained all necessary consents from such person to enable us to collect and process such personal information for the purposes set forth in this Privacy Policy.
We use different methods to collect personal information from and about you, including through:
Direct interactions.
You may give us your personal information by corresponding with us. This includes personal information you provide when you:
- Apply for a job with us;
- Contact us through a form on our Websites or by email;
- Apply for or use our Services;
- Invest in us as a shareholder;
- Subscribe to our newsletter;
- Provide feedback or request information; and
- Voluntarily provide us with your personal information electronically, in person or over the telephone.
Automated technologies or interactions.
As you interact with our Websites, we will automatically collect technical personal information and internet activity information about your equipment, browsing actions and patterns. We collect this information by using cookies, pixels, server logs and other similar technologies. We may also receive technical personal information about you if you visit other websites employing our cookies. Cookies are small pieces of text stored by your web browser.
In addition to this, we also use Google Analytics as part of the analytics cookies on our Websites. Google Analytics is Google’s analytical tool that helps us to understand how users engage with our Websites. The information we collect through Google Analytics is page views, time spent through the Network Services, number of visitors, the source they come from, the pages they have visited, session and Websites usage, the whole in an anonymous form. It uses a set of cookies to collect such information and reports site usage statistics without allowing us to identify individual visitors.
You can opt out of having your activity on the Websites available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing information with Google Analytics about visits activity. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy.
2. Using Personal Information
We use your personal information for the purpose for which it was collected, any other purpose you have consented to and any other purpose permitted by law. The primary purpose for which we collect, use and disclose personal information is to manage our operations and promote our business. This may include using your personal information for any of the following purposes:
Provide you with access to our Websites
- Internet activity information
- Technical personal information
Respond to any communication we receive from you
- Identity personal information
- Contact personal information
Manage shareholder relations
- Shareholder personal information
Provide information about our Services, including project updates and announcements, event invitations, promotions, incentives and other information that we think may interest you, and for other marketing purposes
- Identity personal information
- Contact personal information
- Internet activity information
Help us conduct marketing activities
- Identity personal information
- Contact personal information
- Internet activity information
Processing job applications and conducting recruitment
- Identity personal information
- Contact personal information
- Career profile personal information
To administer our Services and protect the security of our Services
- All categories of information
Continuing to improve your experience with our Websites
- Internet activity information
- Technical personal information
Protect against error or fraud
- All categories of information
Comply with legal and auditing requirements
- All categories of information
Investigate breaches of the Websites terms and conditions or the Privacy Policy
- All categories of information
We may also request express consent to process your personal information in some circumstances.
3. Communication Of Your Personal Information To Third Parties
We may transfer or disclose your personal information to third parties for the purposes above. This may include disclosing information to:
- our related entities and affiliates;
- with our service providers who help us fulfil the purpose for which your personal information was collected, including server hosting providers and platform service providers who help us store the personal information you have provided us;
- with service providers who help us analyse the profiles and characteristics of our Websites’ visitors and job applicants to better understand them;
- with service providers that are marketers and advertisers who help us provide you with news and marketing, including customizing our advertisement and creating lookalike audiences using tools such as Google Adword’s Similar Audiences and Facebook’s Lookalike Audience;
- with service providers who help us with customer support and customer relationship management, including to track your service issues, review and consider job, rental or purchase applications, improve our Services, provide answers and solutions to your queries and concerns and manage our relationship with you;
- to comply with our obligations under any law or regulation, investigation, subpoena or order of a court, tribunal or other administrative or governmental authority;
- with law enforcement or a government institution in order to investigate fraud or potential fraud, as well as any other violation of a law, regulation, or the Websites terms and conditions, or in order to protect the rights, property, or safety of PATH, our customers, users, or our partners; and
- with an acquiring organization in the event of a proposed or actual acquisition of PATH’s business, loans, securities or assets via business combination, amalgamation, plan of arrangement, merger, tender offer or take-over bid or similar transactions or via a liquidation, realization, seizure, or repossession.
We require third party service providers to respect the security of your personal information and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal information for their own purposes; we only permit them to process your personal information for specified purposes and in accordance with our instructions.
4. Cross-jurisdictional Transfers
By providing us with personal information, you acknowledge and agree that your personal information may be transferred to other jurisdictions for processing and storage, including in servers located across Canada, the United States or elsewhere in the world, where laws regarding the protection of personal information may be less stringent than the laws in your jurisdiction. Further, your personal information may be accessible to law enforcement, national security authorities, and the courts of such jurisdictions. Where necessary to make such transfers, we will comply with our legal and regulatory obligations in relation to the personal information.
5. Safeguards
To prevent unauthorized access or disclosure, maintain data accuracy and facilitate the appropriate use of data, PATH uses physical, technological and administrative procedures to attempt to protect the integrity of its Websites and the confidentiality of personal information that it processes. Nevertheless, Internet transmissions are never completely private or secure. PATH cannot be liable for any breaches of confidentiality due to system failures or unauthorized access by third parties.
6. How Long Will We Retain Your Personal Information?
PATH only keeps personal information for as long as necessary and for the purposes it was collected, or for as long as required to comply with any applicable legal obligation and its documents retention policies. The length of time personal information is kept varies according to the nature of the information.
When the personal information collected is no longer required by PATH, the necessary procedures for destroying, deleting, erasing, or converting it into an anonymous form are applied.
In some circumstances, we will anonymise your personal information (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
7. Protection Of Children’s Personal Information
The protection of children’s personal information is extremely important to us. PATH understands that it has a responsibility to protect the privacy of children.
These Websites, our Services and our recruitment program are targeted to, and intended to be used by, adults. We do not knowingly collect any information from persons under the age of 14. If we become aware that we have collected any personal information from a child under the age of 14, we will delete that information. We ask parents and other guardians to monitor their children’s Internet usage in order to protect them.
8. Your Legal Rights
Subject to certain exceptions, as permitted by law, you have the following rights in relation to the personal information we hold about you:
Your right of access
You have the right to access the personal information we hold about you and to receive a general account of our uses of that personal information. Upon receipt of a written request from you, we will provide you with a copy of your personal information, although in certain limited circumstances, we may not be able to make all relevant personal information available to you, for example, where that personal information also relates to another individual. In such circumstances, we will, upon request, provide you with the reasons for such refusal. We will endeavour to deal with all requests for access of personal information in a timely manner.
Your right to rectification
If the personal information we hold about you is inaccurate or incomplete, you are entitled to have it rectified. Where appropriate, such amended personal information will be provided to the parties to whom we are authorized to disclose your personal information. We will endeavour to deal with all requests for rectification of personal information in a timely manner.
Your right to withdraw consent
If we rely on your implicit or explicit consent as our legal basis for processing your personal information, you have the right to withdraw that consent at any time. However, this will not affect the lawfulness of any processing carried out before you withdrew your consent. If you withdraw your consent, we may not be able to provide certain products, services, and information to you. We will advise you if this is the case at the time you withdraw your consent. We may use your information to send important notices or communications regarding orders or contracts for products and services we procure from you or sell to you, even if you have opted out from our marketing communications.
9. Links To Other Websites And Advertising
The Websites may occasionally contain links to other sites not operated by PATH. PATH is not responsible for the privacy practices or the content of those websites. Please be sure to review the privacy policies of those sites.
The Websites may display advertisements or links to third party sites. These advertisements or links may contain cookies placed by those third parties. PATH is not responsible for those advertisements, the websites to which they are linked, or how any other linked sites may use their own cookies or information. For example, cookies received with banner ads may be collected by the company posting the ad on our Websites. Please refer to that company’s privacy policy for further information.
10. What Do You Do If You Have A Complaint Or A Question?
If you would like further information about how we manage your personal information, have any queries or feedback relating to this Privacy Policy, or wish to lodge a complaint, you may contact the office of our Privacy Officer at:
Suite 1774, Four Bentall Centre
1055 Dunsmuir Street, Box 49221
Vancouver, BC V7X 1L2
Tel: (604) 408-5670
Our Privacy Officer is accountable for compliance with applicable privacy laws and is responsible for coordinating the investigation of any complaints and resolving privacy-related issues. The Privacy Officer will manage any complaints received in a timely manner and provide you with a response to your complaint.
You have the right to make a complaint at any time to the relevant privacy regulator. We would, however, appreciate the chance to deal with your concerns before you approach the relevant privacy regulator so please contact us in the first instance. In Canada, you can contact the Office of the Privacy Commissioner of Canada or the relevant provincial privacy commissioner for your province of residence.
11. Changes To This Privacy Policy
From time to time, it may be necessary for us to review and revise this privacy policy. We reserve the right to amend this privacy policy at any time and to notify you by posting an updated version of the privacy policy on our Websites or by contacting you via email, or both.